HISTORY REPEAT - ANOTHER CRAPPY HUMAN HEALTH RISK ASSESSMENT (HHRA) AT CHEMTURA (UNIROYAL)

Here we go again. Apparently the more obvious the need for remediation the more "studies" and "sampling" required. What exactly are the Ontario M.O.E.C.C. trying to do here? Are they hoping to coordinate a sampling round a week or two after the worst storm of the decade scours the creek bottom and flushes more tons of contaminants downstream into the Grand River? We now have some data from 1995-96, 2012, 2013, 2014 and 2015. That said the M.O.E. are still sitting on the 2015 data and refusing to share it. The evidence is overwhelming that more, much more, needs to be done. Instead the M.O.E. are "requesting" another sediment and soil investigation this year "to support a screening level human health risk assessment (HHRA)". What the hell is a "screening level" HHRA? Is that bureaucratese for a HHRA with holes in it big enough to drive a truck through?

The other possibility long practiced by the M.O.E. and other government agencies is to hide the forest with the trees. In other words as bad as 1995-96 and 2012 were hopefully more data at different times of the year, different locations (even slightly), different sampling methods and or simply more data will confuse the picture. Right now with over a quarter of a century of reading technical reports I find simultaneously examining multiple reports to be much more difficult than simply looking at one report at a time. Also the M.O.E. and Chemtura are masters at cherrypicking the results that they want. The more reports, studies, data and sampling the more likely you will find something, somewhere to back up your do little, spend less remediation philosophy.

Approximately thirteen years ago Chemtura, O.K. Crompton or whatever their name was that year, did both an HHRA as well as an ERA or Ecological Risk Assessment for their own property. I would describe both of them as garbage on paper. Dr. Henry Regier and I led the charge with questions and comments that were poorly if at all answered. Dr. Regier with decades of scientific expertise went right to the heart of the Risk Assessment process and found it wanting. He personally went to the M.O.E. offices to interview and discuss the "science" behind Risk Assessments. Dr. Regier has advised that in his opinion the M.O.E. brains behind the HHRA and ERA were out of their depth and had only a basic, peripheral understanding of what they were doing.

The final synopsis of a years long waste of time process for the HHRA was that the Uniroyal/Crompton/Chemtura site was only a hazard to the occasional trespasser (me??) and not to employees or the general public. Regarding the ERA the site was only a hazard to insectivorious shrews on the site who dug down into the earth. Seriously that's what those twits found. Even the M.O.E. have recently expressed skepticism regarding the last go round with Risk Assessments. Dear God save us all from client driven, pony-tailed PhDs who have never found a toxic chemical without some redeeming social values. Meanwhile the M.O.E. are now conceding that diluted contaminants from the Chemtura site miles downstream have the potential to adversely affect recreational users in the creek. What about 24/7 life in the creek? Don't they count anymore? Amphibians, reptiles, insects, the benthic community, fish, and predators all the way up the food chain don't seem to be of concern. My expectation is that if necessary the M.O.E. will continue having Chemtura "study" the environmental disaster until the day the company finally and at long last departs for greener pastures with blunter politicians who aren't trying simultaneously to suck and blow. Corporations are searching for money making opportunities with the least amount of government interference possible. Even so called "democracies" are pathetic at holding corporations accountable. Trade agreements such as NAFTA, TPP etc. exacerbate the shift in power towards money, profits and corporations at the expense of human beings.